Greater Cambridge Local Plan: Proposed Submission

The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.

I write on behalf of Cambridge Biomedical Campus Limited (“CBC Ltd”) to submit representations in response to the Regulation 19 consultation on the Proposed Submission Greater Cambridge Local Plan 2024–2045 (“the Plan”). When adopted, the Plan will form part of the development plan for Greater Cambridge and the basis for decision making.
These representations have been reviewed in the context of the National Planning Policy Framework (NPPF) December 2024, which applies to this Plan as set out at paragraph 1.16 of the draft Local Plan.
The NPPF published on 17 August 2026 provides at Annex A(8) that plans not being prepared under the Levelling-up and Regeneration Act 2023 and the Town and Country Planning (Local Planning) (England) Regulations 2026 are to be produced in accordance with the December 2024 Framework, and the Greater Cambridge Shared Planning Service has confirmed that the Plan will be examined against this Framework.
Paragraph 36 of the December 2024 NPPF provides that a plan is sound if it is:
Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
These representations relate to Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital). CBC Ltd considers that the Plan is legally compliant and that the duty to co-operate has been met and its proposed amendments are directed to soundness of the Plan.
The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.
CBC Ltd are aware that the expansion landowners will be submitting a full response to the Regulation 19 consultation and reserve the right to further comment on this. In particular there are some changes being considered by the expansion landowners to which we would strongly object if formally proposed.

Policy S/CBC: Cambridge Biomedical Campus
CBC Ltd strongly supports the Councils’ recognition of the Campus as a globally significant centre for healthcare, life sciences and clinical research.
CBC Ltd considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive growth that the policy itself seeks. As such, the proposed modifications set out at Tables 1 and 2 of Appendix 1 seek to address these matters by clarifying how growth should take place on the Campus and by strengthening the masterplan-led approach, so that the policy supports the comprehensive, coordinated and enforceable spatial approach that paragraph 29 requires.
Principally, the masterplan is central to the delivery of the policy, but its details are not established. As drafted, paragraphs 10 and 30 require a whole Campus Masterplan prepared “with input from” and “engaging” existing campus landowners and major occupiers. Our members strongly oppose this approach which could allow other parties to develop plans for their assets on the existing campus without their agreement. The proposed amendments at Appendix 1 table 2 require the masterplan to be co-produced with existing landowners and major occupiers so that all parties have certainty as to what is required and when. Furthermore, the requirement for this should remain as a major application on the phase 3 or 4 ‘expansion’ land and not significant development on the existing campus.
CBC Ltd recognises that the exceptional circumstances case justifying the release of greenbelt land for campus expansion needs to be based on guaranteeing the delivery of a world-class place. The centrality of this was contained in letters to the expansion landowners dated 29 February 2024 and 29 April 2025 making clear the conditions under which CBC Ltd could support the case to release greenbelt land (Appendix 3). This required the agreement between all affected parties of an Infrastructure Delivery Strategy (IDS). Unfortunately, despite extensive work to date the nature and extent of this strategy, and the commitments it secures are yet to be settled.

The policy does not deal adequately with future development on the existing Campus in relation to trip generation and wording is proposed to make this clear. There is also suggested additional wording relating to the development of campus wide solutions for securing local employment and affordable workspace.

Regulation 18 Draft Local Plan
CBC Ltd submitted representations to the Greater Cambridge Shared Planning Service at the Regulation 18 Draft Local Plan stage.
This representation is included at Appendix 2 for ease of reference and remains relevant.
Concluding Remarks
I trust that the information provided will be considered as part of the consultation process on the draft Local Plan and look forward to receiving confirmation that this representation has been received.
The matters raised concern the deliverability of a strategic allocation of national significance and cannot, in our view, be resolved in writing alone. CBC Ltd therefore wishes to participate in the examination hearing sessions dealing with Policy S/CBC and the Cambridge Biomedical Campus allocation. It should be noted that if the changes proposed are not adequately reflected then CBC Ltd reserves the right to oppose the principle of the allocation of the greenbelt land.
CBC Ltd also requests to be notified of the submission of the Plan for examination, the publication of the Inspector’s report and the adoption of the Plan.

Land at the Cambridge Biomedical Campus as shown on the Policies Map and indicative Spatial Framework (Figure 54), including land removed from the Green Belt adjoining Babraham Road (shown in Figure 55), is allocated for a mix of uses contributing to health and life sciences, commercial, education and innovation floorspace, including those listed below. The final quantum, distribution and mix of floorspace shall be informed by the Campus Masterplan set out in paragraph 30.

Healthcare provision serving local, regional and international needs, including new and updated NHS buildings and supporting clinical infrastructure;
b.
Approximately 650,000 net square metres (Gross Internal Area, excluding internal and external plant) for additional biomedical, biotechnology and life sciences research and development; related commercial uses; medical research institutes; and higher education uses for academic teaching and research, training facilities supporting the development and retention of healthcare related skills and talent. Other supporting uses including hotels and leisure facilities; and
d. Capacity for approximately 1,000 additional homes on the campus.

I write on behalf of Cambridge Biomedical Campus Limited (“CBC Ltd”) to submit representations in response to the Regulation 19 consultation on the Proposed Submission Greater Cambridge Local Plan 2024–2045 (“the Plan”). When adopted, the Plan will form part of the development plan for Greater Cambridge and the basis for decision making.
These representations have been reviewed in the context of the National Planning Policy Framework (NPPF) December 2024, which applies to this Plan as set out at paragraph 1.16 of the draft Local Plan.
The NPPF published on 17 August 2026 provides at Annex A(8) that plans not being prepared under the Levelling-up and Regeneration Act 2023 and the Town and Country Planning (Local Planning) (England) Regulations 2026 are to be produced in accordance with the December 2024 Framework, and the Greater Cambridge Shared Planning Service has confirmed that the Plan will be examined against this Framework.
Paragraph 36 of the December 2024 NPPF provides that a plan is sound if it is:
Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
These representations relate to Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital). CBC Ltd considers that the Plan is legally compliant and that the duty to co-operate has been met and its proposed amendments are directed to soundness of the Plan.
The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.
CBC Ltd are aware that the expansion landowners will be submitting a full response to the Regulation 19 consultation and reserve the right to further comment on this. In particular there are some changes being considered by the expansion landowners to which we would strongly object if formally proposed.

Policy S/CBC: Cambridge Biomedical Campus
CBC Ltd strongly supports the Councils’ recognition of the Campus as a globally significant centre for healthcare, life sciences and clinical research.
CBC Ltd considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive growth that the policy itself seeks. As such, the proposed modifications set out at Tables 1 and 2 of Appendix 1 seek to address these matters by clarifying how growth should take place on the Campus and by strengthening the masterplan-led approach, so that the policy supports the comprehensive, coordinated and enforceable spatial approach that paragraph 29 requires.
Principally, the masterplan is central to the delivery of the policy, but its details are not established. As drafted, paragraphs 10 and 30 require a whole Campus Masterplan prepared “with input from” and “engaging” existing campus landowners and major occupiers. Our members strongly oppose this approach which could allow other parties to develop plans for their assets on the existing campus without their agreement. The proposed amendments at Appendix 1 table 2 require the masterplan to be co-produced with existing landowners and major occupiers so that all parties have certainty as to what is required and when. Furthermore, the requirement for this should remain as a major application on the phase 3 or 4 ‘expansion’ land and not significant development on the existing campus.
CBC Ltd recognises that the exceptional circumstances case justifying the release of greenbelt land for campus expansion needs to be based on guaranteeing the delivery of a world-class place. The centrality of this was contained in letters to the expansion landowners dated 29 February 2024 and 29 April 2025 making clear the conditions under which CBC Ltd could support the case to release greenbelt land (Appendix 3). This required the agreement between all affected parties of an Infrastructure Delivery Strategy (IDS). Unfortunately, despite extensive work to date the nature and extent of this strategy, and the commitments it secures are yet to be settled.

The policy does not deal adequately with future development on the existing Campus in relation to trip generation and wording is proposed to make this clear. There is also suggested additional wording relating to the development of campus wide solutions for securing local employment and affordable workspace.

Regulation 18 Draft Local Plan
CBC Ltd submitted representations to the Greater Cambridge Shared Planning Service at the Regulation 18 Draft Local Plan stage.
This representation is included at Appendix 2 for ease of reference and remains relevant.
Concluding Remarks
I trust that the information provided will be considered as part of the consultation process on the draft Local Plan and look forward to receiving confirmation that this representation has been received.
The matters raised concern the deliverability of a strategic allocation of national significance and cannot, in our view, be resolved in writing alone. CBC Ltd therefore wishes to participate in the examination hearing sessions dealing with Policy S/CBC and the Cambridge Biomedical Campus allocation. It should be noted that if the changes proposed are not adequately reflected then CBC Ltd reserves the right to oppose the principle of the allocation of the greenbelt land.
CBC Ltd also requests to be notified of the submission of the Plan for examination, the publication of the Inspector’s report and the adoption of the Plan.

Uses section of Policy S/CBC to include new paragraph 13 – Where a requirement arises for:
•An Employment and Skills Plan by Policy WS/IO (creating inclusive employment and business opportunities through new developments); and / or
•Affordable workspace by Policy J/AW Affordable workspace and creative industries;
The delivery of the policy response to meet the requirement should be viewed in the context of the Campus as a whole and how its purpose can be best supported and delivered to maintain the world class status.

I write on behalf of Cambridge Biomedical Campus Limited (“CBC Ltd”) to submit representations in response to the Regulation 19 consultation on the Proposed Submission Greater Cambridge Local Plan 2024–2045 (“the Plan”). When adopted, the Plan will form part of the development plan for Greater Cambridge and the basis for decision making.
These representations have been reviewed in the context of the National Planning Policy Framework (NPPF) December 2024, which applies to this Plan as set out at paragraph 1.16 of the draft Local Plan.
The NPPF published on 17 August 2026 provides at Annex A(8) that plans not being prepared under the Levelling-up and Regeneration Act 2023 and the Town and Country Planning (Local Planning) (England) Regulations 2026 are to be produced in accordance with the December 2024 Framework, and the Greater Cambridge Shared Planning Service has confirmed that the Plan will be examined against this Framework.
Paragraph 36 of the December 2024 NPPF provides that a plan is sound if it is:
Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
These representations relate to Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital). CBC Ltd considers that the Plan is legally compliant and that the duty to co-operate has been met and its proposed amendments are directed to soundness of the Plan.
The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.
CBC Ltd are aware that the expansion landowners will be submitting a full response to the Regulation 19 consultation and reserve the right to further comment on this. In particular there are some changes being considered by the expansion landowners to which we would strongly object if formally proposed.

Policy S/CBC: Cambridge Biomedical Campus
CBC Ltd strongly supports the Councils’ recognition of the Campus as a globally significant centre for healthcare, life sciences and clinical research.
CBC Ltd considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive growth that the policy itself seeks. As such, the proposed modifications set out at Tables 1 and 2 of Appendix 1 seek to address these matters by clarifying how growth should take place on the Campus and by strengthening the masterplan-led approach, so that the policy supports the comprehensive, coordinated and enforceable spatial approach that paragraph 29 requires.
Principally, the masterplan is central to the delivery of the policy, but its details are not established. As drafted, paragraphs 10 and 30 require a whole Campus Masterplan prepared “with input from” and “engaging” existing campus landowners and major occupiers. Our members strongly oppose this approach which could allow other parties to develop plans for their assets on the existing campus without their agreement. The proposed amendments at Appendix 1 table 2 require the masterplan to be co-produced with existing landowners and major occupiers so that all parties have certainty as to what is required and when. Furthermore, the requirement for this should remain as a major application on the phase 3 or 4 ‘expansion’ land and not significant development on the existing campus.
CBC Ltd recognises that the exceptional circumstances case justifying the release of greenbelt land for campus expansion needs to be based on guaranteeing the delivery of a world-class place. The centrality of this was contained in letters to the expansion landowners dated 29 February 2024 and 29 April 2025 making clear the conditions under which CBC Ltd could support the case to release greenbelt land (Appendix 3). This required the agreement between all affected parties of an Infrastructure Delivery Strategy (IDS). Unfortunately, despite extensive work to date the nature and extent of this strategy, and the commitments it secures are yet to be settled.

The policy does not deal adequately with future development on the existing Campus in relation to trip generation and wording is proposed to make this clear. There is also suggested additional wording relating to the development of campus wide solutions for securing local employment and affordable workspace.

Regulation 18 Draft Local Plan
CBC Ltd submitted representations to the Greater Cambridge Shared Planning Service at the Regulation 18 Draft Local Plan stage.
This representation is included at Appendix 2 for ease of reference and remains relevant.
Concluding Remarks
I trust that the information provided will be considered as part of the consultation process on the draft Local Plan and look forward to receiving confirmation that this representation has been received.
The matters raised concern the deliverability of a strategic allocation of national significance and cannot, in our view, be resolved in writing alone. CBC Ltd therefore wishes to participate in the examination hearing sessions dealing with Policy S/CBC and the Cambridge Biomedical Campus allocation. It should be noted that if the changes proposed are not adequately reflected then CBC Ltd reserves the right to oppose the principle of the allocation of the greenbelt land.
CBC Ltd also requests to be notified of the submission of the Plan for examination, the publication of the Inspector’s report and the adoption of the Plan.

Paragraph 23 - The agreed whole Campus masterplan, as required at paragraph 30 must demonstrate how:
a.
The distribution and mix of development achieves optimal transport outcomes, including high levels of site trip internalisation, the spreading of peak hour trips, and high active and public transport mode shares; and
b.
The quantum and mix of development can be delivered within the agreed trip budget. A definitive trip budget based on detailed evidence must be agreed with the Local Highways Authority prior to submission of the outline application. A monitor and manage approach will be taken to ensure that the development remains within the agreed trip budget for the site throughout its delivery.
Future development on the existing Campus should demonstrate that it can occur without giving rise to unacceptable highway impacts.

I write on behalf of Cambridge Biomedical Campus Limited (“CBC Ltd”) to submit representations in response to the Regulation 19 consultation on the Proposed Submission Greater Cambridge Local Plan 2024–2045 (“the Plan”). When adopted, the Plan will form part of the development plan for Greater Cambridge and the basis for decision making.
These representations have been reviewed in the context of the National Planning Policy Framework (NPPF) December 2024, which applies to this Plan as set out at paragraph 1.16 of the draft Local Plan.
The NPPF published on 17 August 2026 provides at Annex A(8) that plans not being prepared under the Levelling-up and Regeneration Act 2023 and the Town and Country Planning (Local Planning) (England) Regulations 2026 are to be produced in accordance with the December 2024 Framework, and the Greater Cambridge Shared Planning Service has confirmed that the Plan will be examined against this Framework.
Paragraph 36 of the December 2024 NPPF provides that a plan is sound if it is:
Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
These representations relate to Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital). CBC Ltd considers that the Plan is legally compliant and that the duty to co-operate has been met and its proposed amendments are directed to soundness of the Plan.
The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.
CBC Ltd are aware that the expansion landowners will be submitting a full response to the Regulation 19 consultation and reserve the right to further comment on this. In particular there are some changes being considered by the expansion landowners to which we would strongly object if formally proposed.

Policy S/CBC: Cambridge Biomedical Campus
CBC Ltd strongly supports the Councils’ recognition of the Campus as a globally significant centre for healthcare, life sciences and clinical research.
CBC Ltd considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive growth that the policy itself seeks. As such, the proposed modifications set out at Tables 1 and 2 of Appendix 1 seek to address these matters by clarifying how growth should take place on the Campus and by strengthening the masterplan-led approach, so that the policy supports the comprehensive, coordinated and enforceable spatial approach that paragraph 29 requires.
Principally, the masterplan is central to the delivery of the policy, but its details are not established. As drafted, paragraphs 10 and 30 require a whole Campus Masterplan prepared “with input from” and “engaging” existing campus landowners and major occupiers. Our members strongly oppose this approach which could allow other parties to develop plans for their assets on the existing campus without their agreement. The proposed amendments at Appendix 1 table 2 require the masterplan to be co-produced with existing landowners and major occupiers so that all parties have certainty as to what is required and when. Furthermore, the requirement for this should remain as a major application on the phase 3 or 4 ‘expansion’ land and not significant development on the existing campus.
CBC Ltd recognises that the exceptional circumstances case justifying the release of greenbelt land for campus expansion needs to be based on guaranteeing the delivery of a world-class place. The centrality of this was contained in letters to the expansion landowners dated 29 February 2024 and 29 April 2025 making clear the conditions under which CBC Ltd could support the case to release greenbelt land (Appendix 3). This required the agreement between all affected parties of an Infrastructure Delivery Strategy (IDS). Unfortunately, despite extensive work to date the nature and extent of this strategy, and the commitments it secures are yet to be settled.

The policy does not deal adequately with future development on the existing Campus in relation to trip generation and wording is proposed to make this clear. There is also suggested additional wording relating to the development of campus wide solutions for securing local employment and affordable workspace.

Regulation 18 Draft Local Plan
CBC Ltd submitted representations to the Greater Cambridge Shared Planning Service at the Regulation 18 Draft Local Plan stage.
This representation is included at Appendix 2 for ease of reference and remains relevant.
Concluding Remarks
I trust that the information provided will be considered as part of the consultation process on the draft Local Plan and look forward to receiving confirmation that this representation has been received.
The matters raised concern the deliverability of a strategic allocation of national significance and cannot, in our view, be resolved in writing alone. CBC Ltd therefore wishes to participate in the examination hearing sessions dealing with Policy S/CBC and the Cambridge Biomedical Campus allocation. It should be noted that if the changes proposed are not adequately reflected then CBC Ltd reserves the right to oppose the principle of the allocation of the greenbelt land.
CBC Ltd also requests to be notified of the submission of the Plan for examination, the publication of the Inspector’s report and the adoption of the Plan.

Paragraph 31 - A comprehensive Campus-wide Masterplan will be expected to:
a. Address key requirements across the Campus such as access and movement, land uses, green and blue infrastructure, scale and massing and densities; and
b. Set out the layout, mix and scale of uses, including the relationship with the existing Campus composition;
c. Evidence a demonstrated understanding of the cumulative needs of people working, visiting and living on the campus, and the infrastructure, services and facilities necessary to deliver a world leading Campus, and how these needs will be met, including proposed phasing and funding approach;
d. Set out full Phasing Plans, including any further planned development or redevelopment in early phases of the Campus and measures for the Phasing Plan to be updated when necessary, in agreement with the Local Planning Authorities;
e. Include an agreed Infrastructure Delivery Strategy, based on open, transparent and credible viability assessments of the expansion land identifying site-specific and strategic infrastructure requirements to help achieve the vision for the Campus as well as wider Campus enhancement set out in the indicative Spatial Framework and masterplan, and demonstrating that this can be funded and delivered through enforceable mechanisms for the coordinated and phased development of the Campus. It must identify appropriate triggers to ensure the timely provision of infrastructure to align with development phasing;
f. Provide a detailed transport assessment including the delivery of sustainable transport and active travel onto and across the Campus;
g. Provide clear and enforceable strategies for delivery, management and stewardship of shared facilities and public realm in the proposed application area;
h. Set out a Community Engagement Strategy, maintained and submitted alongside future planning applications to meaningfully enable local people and stakeholders to inform site wide and phase/neighbourhood specific proposals;
i. Implement an Amenity Strategy, considering the overall contribution of proposals on the quality of place on the Campus; Where appropriate, provide a Meanwhile Use Strategy, identifying opportunities for the meanwhile use of buildings, facilities and other spaces to make efficient use of land while it is awaiting longer-term development; and
k. Identify how Phases 3 and 4 will integrate with the existing Campus and life-science function.

I write on behalf of Cambridge Biomedical Campus Limited (“CBC Ltd”) to submit representations in response to the Regulation 19 consultation on the Proposed Submission Greater Cambridge Local Plan 2024–2045 (“the Plan”). When adopted, the Plan will form part of the development plan for Greater Cambridge and the basis for decision making.
These representations have been reviewed in the context of the National Planning Policy Framework (NPPF) December 2024, which applies to this Plan as set out at paragraph 1.16 of the draft Local Plan.
The NPPF published on 17 August 2026 provides at Annex A(8) that plans not being prepared under the Levelling-up and Regeneration Act 2023 and the Town and Country Planning (Local Planning) (England) Regulations 2026 are to be produced in accordance with the December 2024 Framework, and the Greater Cambridge Shared Planning Service has confirmed that the Plan will be examined against this Framework.
Paragraph 36 of the December 2024 NPPF provides that a plan is sound if it is:
Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
These representations relate to Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital). CBC Ltd considers that the Plan is legally compliant and that the duty to co-operate has been met and its proposed amendments are directed to soundness of the Plan.
The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.
CBC Ltd are aware that the expansion landowners will be submitting a full response to the Regulation 19 consultation and reserve the right to further comment on this. In particular there are some changes being considered by the expansion landowners to which we would strongly object if formally proposed.

Policy S/CBC: Cambridge Biomedical Campus
CBC Ltd strongly supports the Councils’ recognition of the Campus as a globally significant centre for healthcare, life sciences and clinical research.
CBC Ltd considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive growth that the policy itself seeks. As such, the proposed modifications set out at Tables 1 and 2 of Appendix 1 seek to address these matters by clarifying how growth should take place on the Campus and by strengthening the masterplan-led approach, so that the policy supports the comprehensive, coordinated and enforceable spatial approach that paragraph 29 requires.
Principally, the masterplan is central to the delivery of the policy, but its details are not established. As drafted, paragraphs 10 and 30 require a whole Campus Masterplan prepared “with input from” and “engaging” existing campus landowners and major occupiers. Our members strongly oppose this approach which could allow other parties to develop plans for their assets on the existing campus without their agreement. The proposed amendments at Appendix 1 table 2 require the masterplan to be co-produced with existing landowners and major occupiers so that all parties have certainty as to what is required and when. Furthermore, the requirement for this should remain as a major application on the phase 3 or 4 ‘expansion’ land and not significant development on the existing campus.
CBC Ltd recognises that the exceptional circumstances case justifying the release of greenbelt land for campus expansion needs to be based on guaranteeing the delivery of a world-class place. The centrality of this was contained in letters to the expansion landowners dated 29 February 2024 and 29 April 2025 making clear the conditions under which CBC Ltd could support the case to release greenbelt land (Appendix 3). This required the agreement between all affected parties of an Infrastructure Delivery Strategy (IDS). Unfortunately, despite extensive work to date the nature and extent of this strategy, and the commitments it secures are yet to be settled.

The policy does not deal adequately with future development on the existing Campus in relation to trip generation and wording is proposed to make this clear. There is also suggested additional wording relating to the development of campus wide solutions for securing local employment and affordable workspace.

Regulation 18 Draft Local Plan
CBC Ltd submitted representations to the Greater Cambridge Shared Planning Service at the Regulation 18 Draft Local Plan stage.
This representation is included at Appendix 2 for ease of reference and remains relevant.
Concluding Remarks
I trust that the information provided will be considered as part of the consultation process on the draft Local Plan and look forward to receiving confirmation that this representation has been received.
The matters raised concern the deliverability of a strategic allocation of national significance and cannot, in our view, be resolved in writing alone. CBC Ltd therefore wishes to participate in the examination hearing sessions dealing with Policy S/CBC and the Cambridge Biomedical Campus allocation. It should be noted that if the changes proposed are not adequately reflected then CBC Ltd reserves the right to oppose the principle of the allocation of the greenbelt land.
CBC Ltd also requests to be notified of the submission of the Plan for examination, the publication of the Inspector’s report and the adoption of the Plan.

Paragraph 10 - Development proposals must make a positive and meaningful contribution to it becoming a world leading healthcare, life-science and educational cluster. In order to achieve this, a whole Campus Masterplan developed co-produced with all existing landowners and major occupiers across the Campus and approved prior to submission, will be required prior to any major application being approved within land which forms part of Phase 3 or Phase 4 (identified as land proposed for Green Belt release). Given the range of existing and proposed uses and continuous/cyclical nature of the Campus, an Amenity Strategy is required to achieve a thriving and world leading place. Supportive and ancillary uses such as hotels, conference centres, nurseries, sports, leisure, food and beverage, convenience retail, community gardens and food-growing spaces are required across the Campus to achieve this, and proposals that include these uses will need to:
a. Support the needs of the campus users throughout the day and night;
b. Provide services and facilities which are appropriately located across the Campus, in particular at key areas of activity, to reduce the need for people to travel off the Campus;
c. Ensure they do not compromise the operational needs of the Campus; and
d. Enhance the vibrancy of the Campus and the visitor, patient and employee experience.

I write on behalf of Cambridge Biomedical Campus Limited (“CBC Ltd”) to submit representations in response to the Regulation 19 consultation on the Proposed Submission Greater Cambridge Local Plan 2024–2045 (“the Plan”). When adopted, the Plan will form part of the development plan for Greater Cambridge and the basis for decision making.
These representations have been reviewed in the context of the National Planning Policy Framework (NPPF) December 2024, which applies to this Plan as set out at paragraph 1.16 of the draft Local Plan.
The NPPF published on 17 August 2026 provides at Annex A(8) that plans not being prepared under the Levelling-up and Regeneration Act 2023 and the Town and Country Planning (Local Planning) (England) Regulations 2026 are to be produced in accordance with the December 2024 Framework, and the Greater Cambridge Shared Planning Service has confirmed that the Plan will be examined against this Framework.
Paragraph 36 of the December 2024 NPPF provides that a plan is sound if it is:
Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
These representations relate to Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital). CBC Ltd considers that the Plan is legally compliant and that the duty to co-operate has been met and its proposed amendments are directed to soundness of the Plan.
The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.
CBC Ltd are aware that the expansion landowners will be submitting a full response to the Regulation 19 consultation and reserve the right to further comment on this. In particular there are some changes being considered by the expansion landowners to which we would strongly object if formally proposed.

Policy S/CBC: Cambridge Biomedical Campus
CBC Ltd strongly supports the Councils’ recognition of the Campus as a globally significant centre for healthcare, life sciences and clinical research.
CBC Ltd considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive growth that the policy itself seeks. As such, the proposed modifications set out at Tables 1 and 2 of Appendix 1 seek to address these matters by clarifying how growth should take place on the Campus and by strengthening the masterplan-led approach, so that the policy supports the comprehensive, coordinated and enforceable spatial approach that paragraph 29 requires.
Principally, the masterplan is central to the delivery of the policy, but its details are not established. As drafted, paragraphs 10 and 30 require a whole Campus Masterplan prepared “with input from” and “engaging” existing campus landowners and major occupiers. Our members strongly oppose this approach which could allow other parties to develop plans for their assets on the existing campus without their agreement. The proposed amendments at Appendix 1 table 2 require the masterplan to be co-produced with existing landowners and major occupiers so that all parties have certainty as to what is required and when. Furthermore, the requirement for this should remain as a major application on the phase 3 or 4 ‘expansion’ land and not significant development on the existing campus.
CBC Ltd recognises that the exceptional circumstances case justifying the release of greenbelt land for campus expansion needs to be based on guaranteeing the delivery of a world-class place. The centrality of this was contained in letters to the expansion landowners dated 29 February 2024 and 29 April 2025 making clear the conditions under which CBC Ltd could support the case to release greenbelt land (Appendix 3). This required the agreement between all affected parties of an Infrastructure Delivery Strategy (IDS). Unfortunately, despite extensive work to date the nature and extent of this strategy, and the commitments it secures are yet to be settled.

The policy does not deal adequately with future development on the existing Campus in relation to trip generation and wording is proposed to make this clear. There is also suggested additional wording relating to the development of campus wide solutions for securing local employment and affordable workspace.

Regulation 18 Draft Local Plan
CBC Ltd submitted representations to the Greater Cambridge Shared Planning Service at the Regulation 18 Draft Local Plan stage.
This representation is included at Appendix 2 for ease of reference and remains relevant.
Concluding Remarks
I trust that the information provided will be considered as part of the consultation process on the draft Local Plan and look forward to receiving confirmation that this representation has been received.
The matters raised concern the deliverability of a strategic allocation of national significance and cannot, in our view, be resolved in writing alone. CBC Ltd therefore wishes to participate in the examination hearing sessions dealing with Policy S/CBC and the Cambridge Biomedical Campus allocation. It should be noted that if the changes proposed are not adequately reflected then CBC Ltd reserves the right to oppose the principle of the allocation of the greenbelt land.
CBC Ltd also requests to be notified of the submission of the Plan for examination, the publication of the Inspector’s report and the adoption of the Plan.

Paragraph 22 part B - Deliver an exemplar approach to connectivity and movement within and through the site, promoting sustainable transport, inclusive access, and active travel by: b. Setting aside land for and directly delivering the following physical transport measures within the site:
Improvements to key routes for walking, wheeling and cycling, including Francis Crick Avenue, Dame Mary Archer Way, Robinson Way and Puddicombe Way;
iii. Focused enhancements to improve safety at key junctions for all road users, including the Guided Busway / Francis Crick Avenue junction and the Addenbrooke’s roundabout;
iv. A network of Mobility Hubs at key interchanges, including adjacent to Cambridge South station and bus interchange(s). In addition, steps should be taken to safeguard the future delivery of a public transport and active travel connectivity east west along Main Drive, connecting the Addenbrooke’s Roundabout, via Main Drive, to Keith Day Road, recognising that such delivery will likely be beyond the plan period given the ongoing use of the site by the Addenbrooke’s Hospital food court and theatre block. It is recognised that delivery will be subject to significant alternative sources of funding.
Consolidation of new or re-provided car parking into Mobility Hubs wherever possible, providing high-quality cycle parking, shared mobility infrastructure, and accessible transport for all users. New permanent surface parking should be limited, with provision of short-stay drop-off and pickup bays and blue badge spaces sensitively planned for with dropped kerbs with short distances to hospital, research facilities and offices; and
vi. A network of delivery and consolidation hubs and a last mile delivery system, exploring the use of dynamic kerbside management and other emerging technologies.

I write on behalf of Cambridge Biomedical Campus Limited (“CBC Ltd”) to submit representations in response to the Regulation 19 consultation on the Proposed Submission Greater Cambridge Local Plan 2024–2045 (“the Plan”). When adopted, the Plan will form part of the development plan for Greater Cambridge and the basis for decision making.
These representations have been reviewed in the context of the National Planning Policy Framework (NPPF) December 2024, which applies to this Plan as set out at paragraph 1.16 of the draft Local Plan.
The NPPF published on 17 August 2026 provides at Annex A(8) that plans not being prepared under the Levelling-up and Regeneration Act 2023 and the Town and Country Planning (Local Planning) (England) Regulations 2026 are to be produced in accordance with the December 2024 Framework, and the Greater Cambridge Shared Planning Service has confirmed that the Plan will be examined against this Framework.
Paragraph 36 of the December 2024 NPPF provides that a plan is sound if it is:
Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
These representations relate to Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital). CBC Ltd considers that the Plan is legally compliant and that the duty to co-operate has been met and its proposed amendments are directed to soundness of the Plan.
The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.
CBC Ltd are aware that the expansion landowners will be submitting a full response to the Regulation 19 consultation and reserve the right to further comment on this. In particular there are some changes being considered by the expansion landowners to which we would strongly object if formally proposed.

Policy S/CBC: Cambridge Biomedical Campus
CBC Ltd strongly supports the Councils’ recognition of the Campus as a globally significant centre for healthcare, life sciences and clinical research.
CBC Ltd considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive growth that the policy itself seeks. As such, the proposed modifications set out at Tables 1 and 2 of Appendix 1 seek to address these matters by clarifying how growth should take place on the Campus and by strengthening the masterplan-led approach, so that the policy supports the comprehensive, coordinated and enforceable spatial approach that paragraph 29 requires.
Principally, the masterplan is central to the delivery of the policy, but its details are not established. As drafted, paragraphs 10 and 30 require a whole Campus Masterplan prepared “with input from” and “engaging” existing campus landowners and major occupiers. Our members strongly oppose this approach which could allow other parties to develop plans for their assets on the existing campus without their agreement. The proposed amendments at Appendix 1 table 2 require the masterplan to be co-produced with existing landowners and major occupiers so that all parties have certainty as to what is required and when. Furthermore, the requirement for this should remain as a major application on the phase 3 or 4 ‘expansion’ land and not significant development on the existing campus.
CBC Ltd recognises that the exceptional circumstances case justifying the release of greenbelt land for campus expansion needs to be based on guaranteeing the delivery of a world-class place. The centrality of this was contained in letters to the expansion landowners dated 29 February 2024 and 29 April 2025 making clear the conditions under which CBC Ltd could support the case to release greenbelt land (Appendix 3). This required the agreement between all affected parties of an Infrastructure Delivery Strategy (IDS). Unfortunately, despite extensive work to date the nature and extent of this strategy, and the commitments it secures are yet to be settled.

The policy does not deal adequately with future development on the existing Campus in relation to trip generation and wording is proposed to make this clear. There is also suggested additional wording relating to the development of campus wide solutions for securing local employment and affordable workspace.

Regulation 18 Draft Local Plan
CBC Ltd submitted representations to the Greater Cambridge Shared Planning Service at the Regulation 18 Draft Local Plan stage.
This representation is included at Appendix 2 for ease of reference and remains relevant.
Concluding Remarks
I trust that the information provided will be considered as part of the consultation process on the draft Local Plan and look forward to receiving confirmation that this representation has been received.
The matters raised concern the deliverability of a strategic allocation of national significance and cannot, in our view, be resolved in writing alone. CBC Ltd therefore wishes to participate in the examination hearing sessions dealing with Policy S/CBC and the Cambridge Biomedical Campus allocation. It should be noted that if the changes proposed are not adequately reflected then CBC Ltd reserves the right to oppose the principle of the allocation of the greenbelt land.
CBC Ltd also requests to be notified of the submission of the Plan for examination, the publication of the Inspector’s report and the adoption of the Plan.

Paragraph 24 - To support delivery of the agreed campus wide masterplan, a strategic and local transport mitigation plan will be co-developed with all the key landowners and major occupiers across the existing and expanded campus and approved prior to submission, must be prepared by the applicants for Phases 3 or 4 for agreement with the Local Highways Authority and Local Planning Authority. This must include:
a. Sustainable transport measures, including high-quality mobility services that prioritise modal shift;
b. Vehicular transport measures, including site access arrangements and a strategy for managing and restricting through-traffic of private vehicles through;
c. A framework of measures to optimise freight activity as the Campus expands, including implementing data capture devices such as Automatic Number Plate Recognition (ANPR) that can monitor freight activity across the campus, allowing for impacts to be analysed;
d. Infrastructure costing and delivery phasing, demonstrating how the necessary transport measures identified above will be delivered at a time that enables optimal transport outcomes and remains within the agreed trip budget; and
e. Mechanisms for delivery, monitoring and review including potential delivery through Section 106 obligations, or CIL or other appropriate funding mechanisms.

I write on behalf of Cambridge Biomedical Campus Limited (“CBC Ltd”) to submit representations in response to the Regulation 19 consultation on the Proposed Submission Greater Cambridge Local Plan 2024–2045 (“the Plan”). When adopted, the Plan will form part of the development plan for Greater Cambridge and the basis for decision making.
These representations have been reviewed in the context of the National Planning Policy Framework (NPPF) December 2024, which applies to this Plan as set out at paragraph 1.16 of the draft Local Plan.
The NPPF published on 17 August 2026 provides at Annex A(8) that plans not being prepared under the Levelling-up and Regeneration Act 2023 and the Town and Country Planning (Local Planning) (England) Regulations 2026 are to be produced in accordance with the December 2024 Framework, and the Greater Cambridge Shared Planning Service has confirmed that the Plan will be examined against this Framework.
Paragraph 36 of the December 2024 NPPF provides that a plan is sound if it is:
Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
These representations relate to Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital). CBC Ltd considers that the Plan is legally compliant and that the duty to co-operate has been met and its proposed amendments are directed to soundness of the Plan.
The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.
CBC Ltd are aware that the expansion landowners will be submitting a full response to the Regulation 19 consultation and reserve the right to further comment on this. In particular there are some changes being considered by the expansion landowners to which we would strongly object if formally proposed.

Policy S/CBC: Cambridge Biomedical Campus
CBC Ltd strongly supports the Councils’ recognition of the Campus as a globally significant centre for healthcare, life sciences and clinical research.
CBC Ltd considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive growth that the policy itself seeks. As such, the proposed modifications set out at Tables 1 and 2 of Appendix 1 seek to address these matters by clarifying how growth should take place on the Campus and by strengthening the masterplan-led approach, so that the policy supports the comprehensive, coordinated and enforceable spatial approach that paragraph 29 requires.
Principally, the masterplan is central to the delivery of the policy, but its details are not established. As drafted, paragraphs 10 and 30 require a whole Campus Masterplan prepared “with input from” and “engaging” existing campus landowners and major occupiers. Our members strongly oppose this approach which could allow other parties to develop plans for their assets on the existing campus without their agreement. The proposed amendments at Appendix 1 table 2 require the masterplan to be co-produced with existing landowners and major occupiers so that all parties have certainty as to what is required and when. Furthermore, the requirement for this should remain as a major application on the phase 3 or 4 ‘expansion’ land and not significant development on the existing campus.
CBC Ltd recognises that the exceptional circumstances case justifying the release of greenbelt land for campus expansion needs to be based on guaranteeing the delivery of a world-class place. The centrality of this was contained in letters to the expansion landowners dated 29 February 2024 and 29 April 2025 making clear the conditions under which CBC Ltd could support the case to release greenbelt land (Appendix 3). This required the agreement between all affected parties of an Infrastructure Delivery Strategy (IDS). Unfortunately, despite extensive work to date the nature and extent of this strategy, and the commitments it secures are yet to be settled.

The policy does not deal adequately with future development on the existing Campus in relation to trip generation and wording is proposed to make this clear. There is also suggested additional wording relating to the development of campus wide solutions for securing local employment and affordable workspace.

Regulation 18 Draft Local Plan
CBC Ltd submitted representations to the Greater Cambridge Shared Planning Service at the Regulation 18 Draft Local Plan stage.
This representation is included at Appendix 2 for ease of reference and remains relevant.
Concluding Remarks
I trust that the information provided will be considered as part of the consultation process on the draft Local Plan and look forward to receiving confirmation that this representation has been received.
The matters raised concern the deliverability of a strategic allocation of national significance and cannot, in our view, be resolved in writing alone. CBC Ltd therefore wishes to participate in the examination hearing sessions dealing with Policy S/CBC and the Cambridge Biomedical Campus allocation. It should be noted that if the changes proposed are not adequately reflected then CBC Ltd reserves the right to oppose the principle of the allocation of the greenbelt land.
CBC Ltd also requests to be notified of the submission of the Plan for examination, the publication of the Inspector’s report and the adoption of the Plan.

Paragraph 30 - There are a range of matters that will need to be fully addressed before further development will be supported. To address these, a comprehensive masterplan co-produced with all existing landowners and major occupiers across the Campus and approved prior to submission must be prepared and agreed with the Local Planning Authority prior to or alongside the submission of an outline planning application for Phases 3 or 4, in order to demonstrate how any further expansion of the campus will secure the overall objectives for the campus.

I write on behalf of Cambridge Biomedical Campus Limited (“CBC Ltd”) to submit representations in response to the Regulation 19 consultation on the Proposed Submission Greater Cambridge Local Plan 2024–2045 (“the Plan”). When adopted, the Plan will form part of the development plan for Greater Cambridge and the basis for decision making.
These representations have been reviewed in the context of the National Planning Policy Framework (NPPF) December 2024, which applies to this Plan as set out at paragraph 1.16 of the draft Local Plan.
The NPPF published on 17 August 2026 provides at Annex A(8) that plans not being prepared under the Levelling-up and Regeneration Act 2023 and the Town and Country Planning (Local Planning) (England) Regulations 2026 are to be produced in accordance with the December 2024 Framework, and the Greater Cambridge Shared Planning Service has confirmed that the Plan will be examined against this Framework.
Paragraph 36 of the December 2024 NPPF provides that a plan is sound if it is:
Positively prepared – providing a strategy which, as a minimum, seeks to meet the area’s objectively assessed needs, and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development;
Justified – an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence;
Effective – deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than deferred, as evidenced by the statement of common ground; and
Consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the Framework and other statements of national planning policy, where relevant.
These representations relate to Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital). CBC Ltd considers that the Plan is legally compliant and that the duty to co-operate has been met and its proposed amendments are directed to soundness of the Plan.
The modifications set out in Appendix 1 table 1 are those which CBC Ltd considers necessary to make the policy sound and which we have been able to agree with the expansion landowners. At table 2 are those changes which CBC Ltd considers necessary to make the policy sound and which we have been unable to agree with the expansion landowners. The justification for each modification, and the soundness test to which it relates, is set out alongside it.
CBC Ltd are aware that the expansion landowners will be submitting a full response to the Regulation 19 consultation and reserve the right to further comment on this. In particular there are some changes being considered by the expansion landowners to which we would strongly object if formally proposed.

Policy S/CBC: Cambridge Biomedical Campus
CBC Ltd strongly supports the Councils’ recognition of the Campus as a globally significant centre for healthcare, life sciences and clinical research.
CBC Ltd considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive growth that the policy itself seeks. As such, the proposed modifications set out at Tables 1 and 2 of Appendix 1 seek to address these matters by clarifying how growth should take place on the Campus and by strengthening the masterplan-led approach, so that the policy supports the comprehensive, coordinated and enforceable spatial approach that paragraph 29 requires.
Principally, the masterplan is central to the delivery of the policy, but its details are not established. As drafted, paragraphs 10 and 30 require a whole Campus Masterplan prepared “with input from” and “engaging” existing campus landowners and major occupiers. Our members strongly oppose this approach which could allow other parties to develop plans for their assets on the existing campus without their agreement. The proposed amendments at Appendix 1 table 2 require the masterplan to be co-produced with existing landowners and major occupiers so that all parties have certainty as to what is required and when. Furthermore, the requirement for this should remain as a major application on the phase 3 or 4 ‘expansion’ land and not significant development on the existing campus.
CBC Ltd recognises that the exceptional circumstances case justifying the release of greenbelt land for campus expansion needs to be based on guaranteeing the delivery of a world-class place. The centrality of this was contained in letters to the expansion landowners dated 29 February 2024 and 29 April 2025 making clear the conditions under which CBC Ltd could support the case to release greenbelt land (Appendix 3). This required the agreement between all affected parties of an Infrastructure Delivery Strategy (IDS). Unfortunately, despite extensive work to date the nature and extent of this strategy, and the commitments it secures are yet to be settled.

The policy does not deal adequately with future development on the existing Campus in relation to trip generation and wording is proposed to make this clear. There is also suggested additional wording relating to the development of campus wide solutions for securing local employment and affordable workspace.

Regulation 18 Draft Local Plan
CBC Ltd submitted representations to the Greater Cambridge Shared Planning Service at the Regulation 18 Draft Local Plan stage.
This representation is included at Appendix 2 for ease of reference and remains relevant.
Concluding Remarks
I trust that the information provided will be considered as part of the consultation process on the draft Local Plan and look forward to receiving confirmation that this representation has been received.
The matters raised concern the deliverability of a strategic allocation of national significance and cannot, in our view, be resolved in writing alone. CBC Ltd therefore wishes to participate in the examination hearing sessions dealing with Policy S/CBC and the Cambridge Biomedical Campus allocation. It should be noted that if the changes proposed are not adequately reflected then CBC Ltd reserves the right to oppose the principle of the allocation of the greenbelt land.
CBC Ltd also requests to be notified of the submission of the Plan for examination, the publication of the Inspector’s report and the adoption of the Plan.